https://www.taxtmi.com/caselaws?id=179750 The Court upheld the ITAT's decision in favor of the Assessee, emphasizing the appropriateness of the Comparable Uncontrolled Price (CUP) method over the Transactional Net Margin Method (TNMM) for determining the Arm's Length Price (ALP) in international transactions. It accepted the 50:50 profit-sharing ratio as indicative of arm's length pricing, considering the industry norm and the unique business model of the Assessee. The Court dismissed the Revenue's appeals, highlighting the limitations of Rule 10B in such cases and clarifying that the judgment solely addressed the choice between CUP and TNMM methods. en-us Thu, 10 Dec 2015 00:00:00 +0530 Tue, 03 May 2016 11:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179750 The Court upheld the ITAT's decision in favor of the Assessee, emphasizing the appropriateness of the Comparable Uncontrolled Price (CUP) method over the Transactional Net Margin Method (TNMM) for determining the Arm's Length Price (ALP) in international transactions. It accepted the 50:50 profit-sharing ratio as indicative of arm's length pricing, considering the industry norm and the unique business model of the Assessee. The Court dismissed the Revenue's appeals, highlighting the limitations of Rule 10B in such cases and clarifying that the judgment solely addressed the choice between CUP and TNMM methods. Case-Laws Income Tax Thu, 10 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179750